INTM269040 - Non-residents trading in the UK: through UK investment managers, brokers or Lloyd바카라 사이트™s agents: Lloyd바카라 사이트™s members' agents
Where the non-resident is a member of Lloyd바카라 사이트™s (as defined at FA94/S230) and the transaction is carried out in the course of the non-resident바카라 사이트™s underwriting business, a UK agent acting on behalf of the non-resident in relation to the transaction is regarded as an independent agent acting in the ordinary course of his business if they act as member바카라 사이트™s agent or as managing agent of the syndicate in question. The UK agent cannot therefore be treated as the 바카라 사이트˜UK representative바카라 사이트™ of the non-resident Lloyd바카라 사이트™s member (see Who can be the non-resident바카라 사이트™s UK representative? at INTM268020). The underwriting profits will however continue to be taxable in full in the same way as for resident members.